The
Inspector’s Notebook #5
5 tips for complying with noncompliances Take
time now to understand and correct outstanding issues on your
certification contract

By Jim Riddle

Editor’s NOTE:

Certified organic farmers do an odd thing –
they pay people to visit their farms with a critical
eye to assure they are adhering to every aspect
of the USDA’s national organic standard.

The farmers should already be trying to produce,
harvest and market their organic crops, livestock
and related products by these rules. The on-farm
review of fields, facilities and records by an
approved inspector sent by the farmer’s
accredited organic certifier is the critical point
in confirming that the farmer and the farm meet
the organic standards – and can prove it
to anyone who needs to know.

The visits are pivotal for applying farmers to
become certified, and for certified farmers to
keep that certification. For the good of organics,
we want to help build the foundation for effective
inspection visits. We’ve asked Jim Riddle
to provide an inspector’s inside view to
help farmers understand an inspector’s role,
responsibilities and limitations.

Jim
Riddle

In the months ahead, Riddle will elaborate on
many items to help farmers understand regulations
that apply to them, and how to document their
compliance.

Jim Riddle has been on hundreds of farms in the
inspector role, and he’s been inspected
himself during his time as a farmer. His leadership
in bringing professional training to inspectors
helped to earn greater acceptance of organic farming
in the U.S. He serves as vice-chair of the National
Organic Standards Board, which advises the USDA
on organic agriculture policies and regulations.
He has been an organic farmer, gardener, inspector,
educator, policy analyst, author, and consumer.

Jim Riddle serves as vice-chair of the USDA’s
National Organic Standards Board and organic policy
advisor for NewFarm.org. He was the founding chair
of the Independent Organic Inspectors Association
(IOIA).

November
9, 2004: By now, many organic farmers have been
inspected and have signed certification contracts with their
certifying agencies.

If you have any “minor noncompliances” or “issues
of concern” listed in your Certification Contract or
in the letter you received from your certifier, have you made
the necessary corrections?

This is an extremely important step in the certification process.
Your operation has been evaluated to identify areas where
you are noncompliant with the National Organic Program (NOP).
In some instances, you need to respond immediately to those
requirements in order to be granted or to maintain organic
certification. In others, you may need to discontinue using
a prohibited substance or implement a specific record, such
as better documentation of your searches for organic seed.

In our own certified organic vegetable operation, we had
one noncompliance this year…..adding in the phrase “organic”
to our vegetable labels. Joyce uses a computer to print our
labels, so it was easy to insert “organic” into
the product label information. I didn’t need to send
in any verification, but this will be checked by the inspector
next year.

Here are some tips to make sure you comply with all certification
requirements:

Carefully read the certification contract.
Depending on the policies of the certifying agent, you may
need to sign it and send a copy back.

Understand the requirements.If you do not understand what the certifying agent
is requiring, call them up and talk to the person who signed
the letter or contract.

Respond to requests for information.
Your certifying agent may be asking for more information,
such as what inoculant you intend to use on alfalfa seed
or an ingredient label for a livestock health care product
you want to use. The sooner you get this information to
them, the sooner your certification will be completed.

Respond to conditions for certification.
Your certifying agent may request verification of aspects
of your Organic Farm Plan. You may need to obtain signed
statements from neighbors that are not using prohibited
fertilizers or pesticides on your borders, so that you don’t
need to maintain a buffer. If a water test is required because
you are using water to wash organic products, get the sample
into the lab and send results to the certifying agent as
soon as you receive the results. Send any requested verification
in to the certifying agent as soon as possible. Keep the
certifying agent informed as to your timeline if more time
is needed.

Take the time to make the change. If
you need to discontinue a prohibited product, such as a
dairy-cow feed-supplement premix that contains mineral oil,
research an approved substitute. Talk to your livestock
nutritionist, the certifying agent, other organic livestock
producers, or give ATTRA a call (1-800-346-9140 or www.attra.ncat.org).
If a record is required, such as an equipment cleaning log,
go ahead and design that record (or use a sample provided
by your certifying agent). Put it in your ring binder or
folder where you are keeping other records (or on a clipboard
in the equipment shed for easy access). Then it is ready
when you need to use it. ATTRA has examples of many types
of forms for organic farmers, vegetable growers, orchardists,
berry growers, and livestock producers.

Noncompliance requirements will affect your certification
in the future. You will need to show how you corrected the
requirements in next year’s Organic Farm Plan Update
application. The certifying agent will carefully review your
updated plan to check if you made corrections. And the inspector
will go over these issues during the inspection. They may
even be identified as noncompliances again.

Your response is critical to your organic future. If you
do not address minor noncompliances, your certification could
be suspended or revoked. The sooner you make the changes,
the easier your certification will be in the future.